General Management Plan Amendment and Environmental Impact Statement
A General Management Plan Amendment is a document that partially amends an existing General Management Plan (GMP). National Park Service (NPS) policies allow for amending an existing GMP, rather than undertaking a new GMP, to address particular locations or issues. A GMP Amendment is prepared as part of a public planning process.
The planning area for the General Management Plan Amendment covers more than 28,000 acres, including all lands currently under agricultural lease/permit within Point Reyes National Seashore (Point Reyes) and the north district of Golden Gate National Recreation Area (Golden Gate).
The NPS is required by a court-approved settlement agreement (4,799 KB PDF) to complete this plan and issue a record of decision by July 14, 2021. Consistent with the settlement agreement, the General Management Plan Amendment will focus on the park's highest planning priority, the areas of Point Reyes National Seashore and the north district of Golden Gate National Recreation Area where ranching is currently permitted.
The General Management Plan (GMP) Amendment will replace the 1980 Point Reyes National Seashore and Golden Gate National Recreation Area General Management Plan for lands within this GMP Amendment planning area.
Is the National Park Service required to consider and evaluate specific alternatives in the General Management Plan Amendment?
Yes. Under the multiparty settlement agreement, the National Park Service is required to consider and evaluate a no ranching alternative, a no dairy ranching alternative, and a reduced ranching alternative. The General Management Plan Amendment also identifies and analyzes three additional alternatives.
A preferred alternative is the alternative the National Park Service (NPS) believes will best accomplish the purpose and need of the proposed action and meet the NPS mission and responsibility, with consideration to economic, environmental, and technical factors.
The National Park Service (NPS) carefully reviewed, evaluated, and considered comments submitted during each public involvement phase. Public comments informed the development of subsequent phases of the National Environmental Policy Act process, and NPS prepared responses to substantive comments received on the draft environmental impact statement. Appendix P of the final environmental impact statement contain the summaries of substantive comments and responses to those comments. Numerous comments that repeat the same basic message are responded to collectively.
Substantive comments are defined as those that do one or more of the following:
* Question, with reasonable basis, the accuracy of information in the environmental impact statement
* Question, with reasonable basis, the adequacy of the analysis
* Present reasonable alternatives other than those presented in the environmental impact statement
* Cause changes or revisions to the actions considered in the alternatives
No, commenting is not a form of "voting" on an alternative. Comments in favor of or against a particular alternative, or comments that only agree or disagree with National Park Service (NPS) policy are not considered substantive. Although all comments are read and considered in the development of the final environmental impact statement, only substantive comments require a response from the NPS. The number of comments received on an alternative is not a determination of its merit for consideration in the planning process.
A final decision, issued in a document called the record of decision, will occur after a 30-day minimum waiting period and after the National Park Service (NPS) has completed consultation with regulatory agencies. The NPS is required to complete documentation of compliance with other requirements such as Section 7 of the Endangered Species Act with US Fish and Wildlife Service and National Marine Fisheries Service. The NPS anticipates working with regulatory agencies to complete consultation over the next few months. Additional comment periods or public meetings are not planned or required at this stage of the planning process.
On December 15, 2020, the National Park Service (NPS) respectfully requested corrections to factual errors in Apocalypse Cow: The Future of Life at Point Reyes National Park published in the Pacific Sun on December 9, 2020. The Pacific Sun declined, stating there were no factual errors in the article despite the headline being wrong. The park name is Point Reyes National Seashore not Point Reyes National Park.
As we continue the work to finalize the General Management Plan Amendment (GMP Amendment), we find it critical to provide the below list of requested corrections associated with the article's inaccuracies.
1. The name of the park is Point Reyes National Seashore, not Point Reyes National Park.
2. Incorrect statement: "The EIS acknowledges that removing the pollution produced by the ranches would save federally protected or threatened species from extinction, including Coho and Chinook salmon, steelhead, red legged frogs, California freshwater shrimp, Myrtle's silverspot butterflies and snowy plovers."
Correction: This information is not stated in the final environmental impact statement (FEIS). In fact, these species are protected in the park, are not nearing extinction within their respective ranges, and are all influenced by a variety of threats not pertaining to the GMP Amendment.
3. Incorrect statement: "The hard-packed trail edges a fenced preserve for the world's few remaining tule elk, a federally protected species."
Correction: Tule elk are not listed as threatened or endangered under the Endangered Species Act and are not identified for any special federal protections.
4. Incorrect statement: "Five years ago, several hundred tule elk perished of thirst during a drought that dried up the seeps inside this enclosure, according to the Park Service."
Correction: The tule elk did not die of thirst and this was never stated by the NPS. Ongoing drought conditions resulted in a reduction of available water, but surveys have identified that sufficient water was still available for the elk. If there was no water available to the elk at this time, all of the elk would have perished. A more likely regulating factor is the nutritional quality of the forage during drought conditions rather than the availability of water. Poor nutrition itself can result in mortality and can also result in secondary life-threatening health issues, such as weakened immune systems to combat infections, and will lower reproductive rates.
For more information about Tule Elk, please see our Tule Elk at Tomales Point Frequently Asked Questions page.
5. Incorrect statement: "The 250-page report concludes that the ranching industry covering one third of the park should be expanded and protected for economic and cultural reasons."
Correction: The park's preferred alternative (Alternative B, p. 27) does not expand cattle ranching. Instead, it reduces the acreage of active ranching by creating a 2,000-acre Resource Protection Zone. The preferred alternative maintains the current number of existing dairy animals and animal units for beef operations (p. 38).
6. Incorrect statement: "During the 1970s, the feds paid the park's ranching families a fair market value of $57 million ($382 million in today's dollars) for their properties."
Correction: Congress appropriated $57.5 million dollars for acquiring all of the land, waters, and improvements of Point Reyes National Seashore, not the remaining active ranches.
7. Incorrect statement: "Most of the ranchers signed below-market value leases and agreed to vacate in 25 years."
Correction: The park's enabling legislation gives the Secretary of the Interior the discretionary authority to offer agricultural lease/permits. Please see the Enabling Legislation section on p. 3–4 of the FEIS, including:
In 1978, Congress enacted legislation for both Point Reyes and Golden Gate providing standardized language for the leasing of land for agricultural purposes (16 U.S.C. §§ 459c-5(a) and (b) and 16 U.S.C. §§ 460bb-2(j)). These amendments allow NPS to lease agricultural lands subject to any restrictive covenants deemed necessary and directed NPS to first offer such leases to the person who owned or leased the land prior to its acquisition by the United States. NPS uses these statutory authorities to issue agricultural lease/special use permits (lease/permits) for ongoing multi-generational ranching and dairying operations when a rancher’s reserved right expires.
8. Incorrect statement: "But the EIS was not principally researched and written by Park Service employees."
Correction: NPS staff played a major role in researching and writing the GMP Amendment. Please see p. 230 of the FEIS for a complete list of the staff involved.
Beef and Dairy Ranching
Why are there beef and dairy ranches within Point Reyes National Seashore and Golden Gate National Recreation Area?
The park's enabling legislation (26 KB PDF) gives the Secretary of the Interior the discretionary authority to lease federally-owned land that was agricultural prior to its acquisition subject to any restrictions National Park Service deems necessary to accomplish park purposes. Since the park's establishment, every Secretary of the Interior has exercised this authority. In 2012, Secretary of the Interior Ken Salazar asked the NPS to pursue issuing 20-year lease/permits for beef and dairy ranching (4, 746 KB PDF), ultimately leading to this planning process.
Does the federal government own the land where beef ranching and dairying occur in Point Reyes National Seashore and Golden Gate National Recreation Area?
Yes, the federal government owns the land where ranching and dairying operations occur. The enabling legislation for both Point Reyes National Seashore (26 KB PDF) and Golden Gate National Recreation Area (33 KB PDF) allow the National Park Service to acquire ranch lands from willing sellers. As lands were purchased, ranchers could continue beef or dairy operations under either a Reservation of Use and Occupancy (RUO) or an agricultural special use permit at 5-year intervals. Under an RUO, ranchers could retain a 25-year or life estate right to continue ranching in exchange for a portion of the purchase amount. When ROUs expired, ranchers could continue beef and dairy operations with agricultural special use permits at 5-year intervals. As of 2009, the NPS has the authority to offer 5- or 10-year lease/permits for beef and dairy ranching.
In early 2019, Congress addressed ranching in a Joint Explanatory Statement regarding House Joint Resolution 31 (the Consolidated Appropriations Act, 2019) (7,671 KB PDF - see page 19 of Division E, the 324th page of the 609 page PDF). The Congressional statement noted that "multi-generational ranching and dairying is important both ecologically and economically" and is "fully consistent with Congress's intent for the management of Point Reyes National Seashore."
Do the ranches in Point Reyes National Seashore and Golden Gate National Recreation Area have historical significance?
Yes, the Point Reyes Peninsula & Olema Valley Dairy Ranches Historic Districts are listed on the National Register of Historic Places. The 22,237-acre Point Reyes Peninsula Dairy Ranches Historic District consists of seventeen tenant-operated dairy ranches established by the Shafter and Howard families beginning in 1857. The 14,127-acre Olema Valley Dairy Ranches Historic District includes nineteen properties operated by tenants or families beginning in 1856. Together, these districts reflect more than a century of change and modernization in the industry including the evolution from original wood frame milking barns to concrete Grade A sanitary barns of the 1940s.
Yes, the National Park Service works closely with local agricultural organizations, state agencies, natural resource conservation experts, and stakeholder groups such as UC Cooperative Extension, Marin Resource Conservation District, Natural Resources Conservation Service, and Marin Agricultural Land Trust to share information and discuss issues related to ranching.
In order to adhere to various regulatory requirements and park service mandates, the National Park Service range program:
* Monitors various attributes including vegetation, water quality, and ranch infrastructure
* Implements management practices to protect sensitive resources including water quality, and rare, threatened, and endangered species
* Conducts residual dry matter monitoring each fall to get a sense of how much grazing occurred during the year
* Conducts invasive species management
* Conducts permitting for individual management actions and improvements by ranch operators not covered under the lease/permit, such as fence construction and installation of water troughs
How can the National Park Service ensure protection of sensitive resources with continued ranching as proposed in the preferred alternative?
To ensure the protection of natural and cultural resources, the National Park Service would implement a zoning framework on each ranch based on analysis of topography and sensitive resources. Under the Ranchland zone, ranching activities would differ by subzone, with more intensive activities in subzones without sensitive resources. The area of each subzone would differ by ranch and would be field-checked, updated, and modified as appropriate.
* Resource Protection Subzone: approximately 2000 acres excluded from ranching due to sensitive resources
* Range Subzone: approximately 16,900 acres or 65% of lands where grazing is compatible with resource protection objectives but more intensive activities are not
* Pasture Subzone: approximately 9000 acres or 34% of lands where no sensitive resources are known to occur and more intensive ranching activities can take place
* Ranch Core Subzone (designated on the 18 residentially-occupied ranch complexes): approximately 220 acres or less than 1% of lands including the developed complex of buildings and up to 2.5 acres of adjacent disturbed lands
Beef and dairy ranching would continue as the primary agricultural operation on each ranch. Diversification activities would be authorized on the 18 residentially-occupied ranch complexes. These ranchers could pursue specific diversification activities in the Pasture and Ranch Core subzones where no sensitive resources are known to occur.
* Pasture and Ranch Core subzones: up to 500 chickens, up to 50 sheep or 60 goats with an equivalent cattle reduction
* Ranch Core Subzone: up to 2.5 acres of non-irrigated crops, and also ranch tours, farm stays
In the Ranch Core subzone, ranch-specific proposals for small-scale processing and sale of products produced on the ranch; other livestock such as pigs; horse boarding; and irrigated crops would be considered on a case-by-case basis subject to the submission of detailed proposals and following additional review and compliance.
Any new diversification of livestock or crops specifically prohibits ranchers from harming or harassing wildlife, including predators. Ranchers could use livestock guardian animals with established mitigation measures. Ranchers could also fence crops to exclude wildlife. Temporary electric fencing could be used for livestock management in the Pasture subzone.
The preferred alternative authorizes lease/permits with terms up to 20 years for the existing 24 beef and dairy ranch operations on approximately 26,100 acres. The plan does not expand cattle numbers or active acres of ranching in the park.
Can ranchers participate in greenhouse gas mitigation or carbon sequestration practices often referred to as carbon farming in the preferred alternative?
Yes. Appendix F identifies USDA Natural Resources Conservation Science practice standards that have greenhouse gas mitigation and/or carbon sequestration benefits on farms and ranches, including Tree/Shrub Establishment, Conservation Cover, Riparian Forest Buffer, Riparian Herbaceous Cover, Critical Area Planting, Windbreak/Shelterbelt Establishment, Nutrient Management, Solid/Liquid Waste Separation Facility, Residue and Tillage Management, Grassed Waterway, and Filter Strip.
There are a mix of authorizations currently. Four ranch families hold 10-year authorizations. There are also two remaining life estates. Under the terms of the settlement agreement, the National Park Service issued lease/permits to ranchers who are party to the agreement for terms not to exceed five years from the date the agreement was approved on July 14, 2017. These lease/permits expire on July 14, 2022. Finally, ranchers who did not sign the settlement agreement operate on 1-year authorizations.
In the event an existing rancher decides to discontinue ranching, the National Park Service would follow the succesion policy that is consistent with multigenerational ranching in the planning area.
There are more than 750 tule elk in three distinct herds at Point Reyes, two of which are located in the planning area. The National Park Service conducts a tule elk census at the end of each calendar year. In 2019, there were 439 elk in the tule elk herd (not addressed in this plan), 174 elk in Limantour herd, and 138 in the Drakes Beach herd. The preferred alternative maintains all three tule elk herds.
Tule elk in the Drakes Beach area would be managed at a population threshold of 120 elk which represents a stable and viable population level and is consistent with desired conditions. Lethal methods, or if practicable, translocation outside of the park would be used to maintain the herd at this population threshold.
Management of the Limantour herd would be based on not allowing new herds to establish on leased ranch lands. Male elk would continue to be present on ranch lands. Areas of high elk concentration would be monitored and managed in response to localized resource impacts. National Park Service would use a graduated management response for the Limantour herd, including standard and aggressive hazing techniques and the potential for lethal removal of individual elk. No population level management actions would be taken for the Limantour herd.
How did the National Park Service arrive at a population threshold of 120 adult elk for the Drakes Beach herd in the preferred alternative?
The preferred alternative proposes management of the Drakes Beach herd at a stable and viable population level compatible with desired conditions. The population threshold of 120 adult elk is based on consultation with the California Department of Fish & Wildlife, estimated forage consumption by elk, forage productivity on ranches, time elk spend on ranches, and NPS capacity to manage elk. The National Park Service estimates the removal of 12 to 18 elk annually by staff or trained volunteers.
Could the National Park Service translocate the elk from the Drakes Beach herd beyond the population threshold outside of the park instead of using lethal removal?
Currently, the State of California does not allow the translocation of elk outside of the park because of concerns of spreading Johne's disease. The California Department of Fish and Wildlife's comment letter on the draft EIS reads in part, "Translocation of elk out of PRNS [Point Reyes National Seashore] is not a viable option for population management due to the potential for translocation of diseases, short and long-term costs, risk to staff or contractors, and risk to animals."
How does the proposed management of the Drakes Beach herd in the preferred alternative compare to tule elk management by the California Department of Fish & Wildlife throughout the state?
The preferred alternative proposes lethal removal or translocation, if practicable, of 12–18 elk/year from the Drakes Beach herd. The elk management approach in the preferred alternative is consistent with how tule elk herds are managed by the California Department of Fish & Wildlife (CDFW), and is in line with the Elk Conservation and Management Plan (2018) for the State of California. CDFW allocated 332 elk tags in 2019 for lethal removal through recreational hunting throughout California.
Yes, elk are managed by lethal removal at other National Park Service units including Rocky Mountain National Park, Wind Cave National Park, and Theodore Roosevelt National Park.
Tule elk are native and endemic or limited to the State of California. There are currently approximately 5,700 tule elk in California. Tule elk are not listed by the State of California or the Federal Government as threatened or endangered species.
Fecal indicator bacteria are species such as E. coli that live in the gut of warm-blooded animals and are introduced to the environment through fecal matter. Although most fecal bacteria are not harmful to humans, water quality testing often uses fecal indicator bacteria as a sign that harmful bacteria, known as pathogens, may be present. Inputs of fecal indicator bacteria can come from a variety of sources including livestock, humans, pets, and wildlife. Fecal indicator bacteria are found in the natural environment, but high concentrations in surface waters often indicate inputs or runoff from developed or agricultural areas.
What is National Park Service (NPS) doing to address water quality in the ranching areas of Point Reyes and Golden Gate?
To date, the National Park Servic has overseen implementation of more than 170 management activities intended to improve resource conditions, including water quality, on lands under agricultural lease/permit managed by Point Reyes National Seashore. These projects were completed in cooperation with ranch operators and other partners including the Marin Resource Conservation District, USDA Natural Resources Conservation Service, and San Francisco Bay Regional Water Quality Control Board. These management activities include fencing to exclude livestock from waterways or limit time spent in certain locations; controlled stream crossings to direct livestock across waterways at established locations; water supply for off-stream livestock drinking water; ranch infrastructure improvements such as road rehabilitation, roofs and gutters; waterway stabilization projects to reduce erosion; and riparian and upland vegetation planting (See Figure 4 of Appendix A in the FEIS's Appendices [49.4 MB PDF]). Identification and prioritization of additional management activities to improve water quality conditions is ongoing. Additionally, herbaceous plant material on ranches is monitored by the NPS each fall before the onset of winter rains, with a goal of maintaining an average of 1200 pounds per acre on the ground, to protect from soil erosion and stimulate the next season's vegetative growth. (See the Bartolome, et al., report published in 2015, and specifically Updated Figure A.2 the latest monitoring results.)
The San Francisco Bay Area Network Inventory and Monitoring Program conducts monthly monitoring in the Olema Creek watershed. Water quality monitoring is also conducted monthly in Lagunitas Creek tributaries and Pine Gulch Creek, but alternates watersheds every two years, so after eight years, each water body will have four years of monitoring. Measured water quality parameters include water temperature, pH, conductivity, dissolved oxygen, turbidity, nitrate, total Kjeldahl nitrogen, and fecal indicator bacteria (E. coli and fecal coliform).
In addition, National Park Service staff collect samples at the same Olema Creek watershed monitoring stations mentioned above for five consecutive weeks in winter and five consecutive weeks in summer. These samples are analyzed for fecal coliform concentration to inform the San Francisco Bay Regional Water Quality Control Board's Tomales Bay Pathogen Total Maximum Daily Load (TMDL) program.
The Tomales Bay Watershed Council regularly monitors eleven tributary sites and four sites on Tomales Bay to document the long-term water quality trends in tributaries and Tomales Bay, including sites within Point Reyes National Seashore. The Tomales Bay Watershed Council also participates in monitoring to inform the TMDL program discussed above.
The six organic dairies within Point Reyes National Seashore are required to conduct surface water sampling during or directly following three major storm events per year to comply with regulation of Confined Animal Facilities by the San Francisco Bay Regional Water Quality Control Board. Sampling typically occurs where watercourses leave lands used for dairy operations, and includes measurements of water temperature, pH, specific conductance, and total ammonia nitrogen.
Are there long-term trends in water quality in the Olema Creek watershed, where many of the Golden Gate ranches are located?
The University of California Cooperative Extension, in partnership with Point Reyes National Seashore, published an of analysis of fecal indicator bacteria data collected in the Olema Creek watershed in the peer-reviewed journal Sustainability. This study found the mean concentrations of fecal coliform declined by over 95% from 1999–2017. This reduction was concurrent with 40 best management practices implemented on ranches intended to improve water quality during the same time period.
Lewis, D.J.; Voeller, D.; Saitone, T.L.; Tate, K.W. Management Scale Assessment of Practices to Mitigate Cattle Microbial Water Quality Impairments of Coastal Waters. Sustainability. 2019, 11, 5516. Available at https://doi.org/10.3390/su11195516 (accessed 18 September 2020).
An analysis by NPS staff of water quality data collected in several coastal watersheds, including Kehoe Creek, Abbotts Lagoon, and Home Ranch Creek, indicates fecal indicator bacteria concentrations declined from 1999–2013 at 13 water quality stations downstream of management activities implemented on grazed lands during the monitoring period. There was no trend in turbidity (a measure of water clarity), but it was generally low, with approximately 92% of turbidity results collected between 2010–2013 in these coastal watersheds below a turbidity threshold representing unlikely harm to aquatic life (Voeller et al. 2020). This new trend analysis provides updated information for some of the parameters in the coastal watersheds described in Pawley and Lay 2013, which only looked at data from 1999–2005.
No long term analysis has been conducted by the San Francisco Bay Area Network Inventory and Monitoring Program to date, however they have produced a number of annual and biennial reports that provide snapshots of conditions.
Tomales Bay Watershed Council also produced a summary report of monitoring conducted in the Tomales Bay watershed between 2007–2012, which includes stations in the park.
Carson, Rob 2013. Tomales Bay Wetlands Restoration and Monitoring Program 2007–2012 Final Water Quality Technical Report and Program Summary. Tomales Bay Watershed Council Foundation prepared for California State Water Resources Control Board SRF Project No. C-06-6926-110. Available at http://www.tomalesbaywatershed.org/assets/2011_12_tbwc_finalwqreport_complete_finalv4_sm.pdf (accessed 18 September 2020).
A website called The Revelator reviewed publicly available water quality data collected and analyzed for E. coli from October 2012 to October 2017, and retained the single highest result from each individual monitoring station. From this, several isolated single sample results from the Kehoe Creek watershed appeared in their "10 most contaminated locations" map for the State of California. These single samples were collected at stations positioned by NPS in order to identify and address water quality concerns below high use portions of dairies such as corrals and feeding areas. A full analysis of water quality data collected at these stations from 1999–2013 conducted by NPS indicates fecal indicator bacteria concentrations have been reduced over time, concurrent with the implementation of best management practices on ranches in the watershed (Voeller, et al. 2020. See Appendix L in the FEIS's Appendices (49.4 MB PDF)).
Last updated: September 24, 2021